County Assessors have the advantage of being able to calibrate their models specifically for one market, allowing for a more tailored and precise approach. The OCC, FDIC, NCUA, CFPB, and FHFA (collectively, the Agencies) are adopting a final rule to implement AVM quality control standards mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The quality control standards apply to mortgage originators and secondary market investors in determining the value of a dwelling that is the collateral for mortgage financing. Under the final rule, institutions involved in specific credit decisions or securitization activities are required to...
By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge exorbitant prices and pocket the difference (as shown in Figures 1 through 10), exploiting the consumer’s lack of knowledge. Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s Request for Information on Fees Imposed in Residential Mortgage Transactions. The growth of Appraisal Management Companies (AMCs) in the wake of the 2008 financial crisis was driven by a well-intentioned but ultimately misguided belief that they could help “ensure the integrity and independence” of property valuations. The reasoning...
Reforming the appraisal review process is essential to maintaining the integrity of the real estate market and protecting consumers and homeowners. In mortgage financing, the appraisal process is often seen as the foundation of accurate property valuation and market stability. However, beneath this façade of reliability lies a troubling rift: while real estate appraisers must navigate stringent licensing protocols and scrutiny, the individuals reviewing the appraisals often operate with minimal oversight, instead leaning heavily on automated systems and algorithms. This stark disparity not only undermines the credibility of the review process but also revives the threat of past missteps, once...
She went from viewing occupational licensing as a necessary means to protect the safety and welfare of the public to a cynical tool promoted by established businesses to erect barriers against innovation and competition. Her experience as a licensed real property appraiser in West Virginia turned out to be the perfect training ground for the study of public corruption, restraint of trade and government overreach. Who would have thought it? After 27 years of being whipsawed by West Virginia’s notorious appraiser-licensing apparatus, the Appraisal Foundation – and the latter’s continually changing copyrighted standards – and a complicit federal monitor, Lori...
AMC strictly prohibits the use of third party services. A recent review of an engagement letter from a large national appraisal management company revealed something pretty peculiar… “An appraiser is prohibited from using any third party services.“ Wait, What? No third party services? I am no attorney, and certainly do not know all the aspects of law, but it seems that the definition of third party services is pretty self-explanatory. To be sure I am not mistaken; I researched the definition of third party. FreeDictionary.com: “A person who is not a party to a contract or a transaction, but has...
Impact of the Home Valuation Code of Conduct on Appraisal and Mortgage Outcomes During the housing crisis, it came to be recognized that inflated home mortgage appraisals were widespread during the subprime boom. The New York State Attorney General’s office investigated this issue with respect to one particular lender and Fannie Mae and Freddie Mac. The investigation resulted in an agreement between the Attorney General’s office, the government-sponsored enterprises (GSEs), and the Federal Housing Finance Agency (the GSEs’ federal regulator) in 2008, in which the GSEs agreed to adopt the Home Valuation Code of Conduct (HVCC). Using unique data sets...
Proposed Federal Regulation of Appraisal Management Companies (Minimum Requirements for AMCs) I hear a lot from appraisers concerning their interactions with various appraisal management companies (AMCs). Many keep wondering why appraisers are licensed and strictly regulated while it seems that AMCs for the most part have been left to do whatever they want. That was the case for a while; today the majority of states have already imposed regulations on AMCs. Currently, as part of the Dodd-Frank Act, a group of agencies are working together to set federal guidelines for AMCs. They are looking for feedback on these proposals and...
NAIHP acknowledges neither HVCC nor Appraiser Independence rules require the use of AMC’s. The conflict of interest rules contained in the “Interim Final Rule on Appraiser Independence,” were designed to establish a firewall between a loan production department ordering valuations of residential real estate and appraisers, who perform valuations. The Federal Reserve Board (FRB), who established the Interim Final Rule to replace the Home Valuation Code of Conduct (HVCC) in October of 2010, recognized it was not always practical to separate these functions in small financial institutions, which is why the FRB created two sets of firewall requirements: one for...
Banks aren’t playing by the rules PHOENIX (CBS5) – Mortgage lenders and big banks share much of the blame for this country’s housing crash. So you would thing that they have learned their lesson after cheating the system with bad loans and shady business practices. But Jason Barry has uncovered a whole new way banks aren’t playing by the rules. Clay Gregory is a Valley home appraiser who is spending a lot of time at home these day, but it’s not by choice. “I was put in a position where they pretty much demanded information from me or they were threatening...
